At KOSMILZE, Inc., we’re all about people being healthy. We appreciate that you are trusting us with certain information, which might be important to you. We strive to be transparent about how we use it.

 

Here we describe the privacy practices and policies for our business applications, software, websites, APIs, products, and all services (the “Services”). You will learn about the data we collect, how we use it, the controls we provide you over your information, and the measures we take to keep it safe.

 

Information We Collect

When you subscribe to our Services, we receive the following types of information: your user name, and or your name; your age; your Gender; your Google Analytic Data; and your Teeth Whitness Score.

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INFORMATION PROVIDED TO US

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ACCOUNT INFORMATION

Certain information is required to create an account on our Services, such as your name, Username, email address, password, age, date of birth, gender selection, and in some cases your mobile telephone number. This is the only information required to create an account with us. You may also choose to offer additional types of information, such as a profile photo, biography, country information, and community username.

 

ADDITIONAL INFORMATION

To help improve your experience, or enable certain features of the Services, you may choose to provide us with additional information, like your logs for WHITENING PRODUCTS USED.

 

If you contact us or participate in a survey, contest, or promotion, we gather certain information that you submit, such as your name, contact information, and message(s).

 

ANY PAYMENT INFORMATION

We do not have any purchase options on our app or on our site. We are not responsible for purchases made from the links that may originate from our application.

 

INFORMATION RECEIVED FROM USE Of THE SERVICES

 

DEVICE INFORMATION

Your device collects data on your teeth whiteness score® (Smile Score). The data collected varies depending on which device you utilize. When your device syncs with our applications or software, data recorded on your device is transferred from your device to our servers.

 

USAGE INFORMATION

When you access or use our Services, we receive certain usage and/or network activity information. This may include information about your interaction with the Services. For example, when you view or search our content, install applications or software, create or log into your account, pair your device to your account, or open or interact with the KOSMILZE. Thus, we might obtain your Logging in platform information, such as Facebook, wechat, weibo etc. If you are logging in using social media, you may suspend our access to your social media account.

 

INFORMATION RECEIVED FROM THIRD-PARTIES

If you choose to connect your account on our Services to your account on another service, we may receive information from the other service. For example, if you connect to Facebook or Google, we may receive information like your name, profile picture, age range, language, email address, and friends list.

 

HOW WE USE INFORMATION

We use certain information we collect for the following purposes.

 

TO PROVIDE AND MAINTAIN THE SERVICES

Using certain information we collect, we are able to deliver the Services to you and honor our contract with you. For example, we need to use your information to provide you with your KOSMILZE teeth whiteness activity, and other trends, which enable the community features of the Services.

 

IMPROVE, PERSONALIZE, AND DEVELOP THE SERVICES

We use certain information we collect to improve and personalize the Services and to develop new ones. For example, we use the information to troubleshoot and protect against errors, perform data analysis and testing, conduct research and surveys, and develop new features for the Services.

 

When you allow us to collect precise location information, we use that information to provide and improve features of the Services, such as recording where a teeth whitening record took place, or mapping an activity.

 

We also use your information to make inferences and show you more relevant content. Here are some examples:

 

• Information like your whitening activity helps us recommend products and remind you when you have not recently checked your score. 

• Based on your  score, we may provide you with customized insights to help you improve your smile.

• We may provide certain anonymized bulk data to third-parties for marking and research purposes.

 

COMMUNICATIONS WITH YOU

We use your information when needed to send you Service notifications and respond to you when you contact us. We also use your information to promote new features or products that we think you might be interested in.

 

RESEARCH AND PARTNERS

We use the information collected to better understand whitening behaviors. We may share this information with our partners to improve their products.

 

PROMOTING SAFETY AND SECURITY

We use certain information we collect to promote the safety and security of the Services, our users, and other parties. For example, we may use the information to authenticate users, protect against fraud and abuse, respond to a legal request or claim, conduct audits, and enforce our terms of service and policies.

 

We utilize Google Analytics, which is anonymized.
 

HOW INFORMATION IS SHARED

We never sell the  names of our users. We do not share your personal information, except in the limited circumstances described herein.

 

WHEN YOU AGREE TO SHARE

You may direct us to disclose your information to others. This includes sharing your Score and other information onto social media.

 

EXTERNAL PROCESSING

We transfer information to our corporate affiliates, service providers, and other partners who process it for us, based on our instructions, and in compliance with this policy and any other appropriate confidentiality and security measures. These partners provide us with services globally, including for customer support, information technology, payments, sales, marketing, data analysis, research, and surveys.

 

LEGAL REASONS AND TO PREVENT HARM

We may preserve or disclose information about you to comply with a law, regulation, legal process, or governmental request, to assert legal rights or defend against legal claims, or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms of service, or threats to the security of the Services, or the physical safety of any person.

 

Our policy is to notify you of legal process seeking access to your information, such as search warrants, court orders, or subpoenas, unless we are prohibited by law from doing so. In cases where a court order specifies a non-disclosure period, we provide delayed notice after the expiration of the non-disclosure period. Exceptions to our notice policy include exigent or counterproductive circumstances. For example, when there is an emergency involving a danger of death or serious physical injury to a person.

 

We may share non-personal information that is aggregated or de-identified, so that it cannot reasonably be used to identify an individual. We may disclose such information publicly and to third-parties. For example, in public reports about exercise and activity, to partners under agreement with us, or as part of the community benchmarking information we provide to users of our subscription services.

 

If we are involved in a merger, acquisition, or sale of assets, we will continue to take measures to protect the confidentiality of personal information and give affected users notice before transferring any personal information to a new entity. We reserve the rights to partner with additional parties and share data with our partners.

 

RIGHT TO ACCESS YOUR PERSONAL DATA

We provide you with access and control certain personal data. If you live in certain jurisdictions, you may have legal rights with respect to your information. By logging into your account, you can access much of your personal information, including records with your Scores. You can edit and delete certain personal information. You may contact us via email to delete your account.

 

DATA RETENTION POLICY

We keep your account information, email address(s), and password, for as long as your account is in existence, because we need it to operate your account. In some cases, when you give us information for a feature of the Services, we delete the data after it is no longer needed for the feature. We do reserve the right to retain your whiteness scores for research, assessment and analysis. We also keep information about you and your use of the Services for as long as necessary for our legitimate business interests, for legal reasons, and to prevent harm, including as described in our Terms of Service.

 

ANALYTICS AND ADVERTISING SERVICES PROVIDED BY OTHERS

We work with partners who provide us with analytics and advertising services. This includes helping us understand how users interact with the Services, serving advertisements on our behalf across the internet, and measuring the performance of those advertisements.

 

POLICIES FOR CHILDREN

We appreciate the importance of taking additional measures to protect the privacy of children.

 

Persons under the age of 15, or any other minimum age in the jurisdiction where that person resides, are not permitted to create accounts. We anonymize all names, but we do retain location, sex, age, use and score related data. Use of the Services by a minor, as determined in the jurisdiction of the minor’s residency, must be undertaken solely with parental consent and parental supervision.

 

INFORMATION SECURITY

We work hard to keep your data safe. We utilize a combination of technical, administrative, and physical controls to maintain the security of your data. Our efforts are reasonable and undertaken to conform with industry standards for similar applications. No method of transmitting or storing data is completely secure, however.

 

INTERNATIONAL OPERATIONS AND DATA TRANSFERS

We may operate internationally and transfer information to and within the United States and other countries for the purposes described in this policy.

 

We rely upon multiple legal bases to lawfully transfer personal data around the world. These include your consent, the EU-US and Swiss-US Privacy Shield, and EU Commission approved model contractual clauses, which require certain privacy and security protections. KOSMILZE, Inc. complies with the Privacy Shield principles regarding the collection, use, sharing and retention of personal information.

 

KOSMILZE, Inc. may be subject to the oversight of the US Federal Trade Commission and remains responsible for personal information that we transfer to others who process it on our behalf.

 

Please note that the countries where we operate may have privacy and data protection laws that differ from, and are potentially less protective than, the laws of your country. You agree to this risk when you create a KOSMILZE, Inc. account. If you later wish to withdraw your consent, you can delete your KOSMILZE, Inc. account.

 

EUROPEAN PRIVACY DISCLOSURES

If you live in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, please review our additional privacy disclosures under the European Union’s General Data Protection Regulation (“GDPR”).

 

HEALTH AND OTHER SPECIAL CATEGORIES OF PERSONAL DATA

We do not collect health data.

 

OUR LEGAL BASES FOR PROCESSING PERSONAL DATA

For personal data subject to the GDPR, we rely on several legal bases to process the data, including:

 

• When you have given your consent, which you may withdraw at any time. 

• When the processing is necessary to perform a contract with you.

• Our legitimate business interests, such as in improving, personalizing, and developing the Services, marketing new features or products that may be of interest, and promoting safety and security.

 

CALIFORNIA PRIVACY DISCLOSURES

If you are a California resident, please review the following additional privacy disclosures under the California Consumer Privacy Act ("CCPA").

 

HOW TO EXERCISE YOUR LEGAL RIGHTS

You have the right to understand how we collect, use, and disclose your personal information, to access your information, to request that we delete certain information, and to not be discriminated against for exercising your privacy rights.

 

INFORMATION CATEGORIES WE COLLECT FOR BUSINESS PURPOSES

As described above, we may collect categories of personal information listed below. We receive this information from you, your device, and/or your use of the Services. The categories are as follows:

 

• Identifiers, like your name or username, email address, mailing address, phone number, IP address, account ID, device ID, , and other similar identifiers.

• Demographic information, such as your selected gender and age.

• Internet or other electronic network activity information, such as the usage data we receive when you access or use our Services. This includes information about your interactions with the Services and about the devices and computers you use to access the Services.

• Your teeth whiteness score.

• Other information that you provide, including account information.

• Teeth whitening products you use, and frequency of use.  

 

TERMINATION

Termination of your account is handled through our Terms of Services policy.

 

CHANGES TO THIS POLICY

We will notify you before we make material changes to this policy and give you an opportunity to review the revised policy before deciding if you would like to continue to use the Services.

 

HOW TO CONTACT US

You may contact us via admin@kosmilze.com.